• A written first-aid program outlines the plan, purpose, administrative duties, designated first-aid personnel, and more.
• All injuries and illnesses that result in medical treatment must be recorded in OSHA 300 logs.
• OSHA recommends that an emergency response plan include preparing for active shooter incidents, such as shelter-in-place and evacuation procedures.

Recordkeeping

Record on the Occupational Safety and Health Administration (OSHA) 300 logs all injuries/illnesses that result in medical treatment beyond first aid. See OSHA’s 1904.7(b)(5)(ii) for a definition of first aid for recordkeeping purposes.

Plan

The following is an example of what should be included in a First-Aid Program.

Purpose

The First-Aid Program should describe the purpose of the program and ensure that the company first aid program meets OSHA’s requirements at 1910.151, Medical Services and First Aid.

Administrative duties

The First-Aid Program should identify a First-Aid Program Administrator that is responsible for establishing and implementing the First-Aid Program. This person has full authority to make necessary decisions to ensure the success of the program.

Designated first-aid personnel

The First-Aid Program should identify first-aid personnel that are readily available for advice and consultation on health matters.

The National Emergency Medical Service (EMS) Education and Practice Blueprint lists the following first-aid designations:

• First-aid provider: Occupationally required to be trained in first aid even though they may not be specifically obligated by law to perform first aid. Responds as a “Good Samaritan.” Uses a limited amount of equipment to perform an initial assessment and provide immediate life support and care while awaiting the arrival of emergency medical services (EMS).
• First responder: Uses a limited amount of equipment to perform initial assessment and intervention and is trained to assist other EMS.
• Emergency medical technician (EMT)-Basic: The second level of professional emergency medical care provider. Qualified to function as the minimum staff for an ambulance.
• EMT-Intermediate: The third level of professional emergency medical care provider. Can perform essential advanced techniques and administer a limited number of medications.
• Paramedic: The fourth level of professional emergency medical care provider. Can administer additional interventions and medications.

Keep a list of the people trained and responsible for rendering first aid at the facility. The list should include their name, title, first-aid designation, department, phone number, and their responsibilities and roles.

Hazard and medical services assessment

Assess the job location for hazards to determine whether any pose the risk of a life-threatening or permanently disabling injury or illness. Keep a list of the types of injuries or illnesses that are likely to occur and the department they are likely to occur in.

Document the name and location of the nearest hospital or clinic. A facility is considered in “near proximity” if it is within 3-4 minutes away.

When hazards or locations change, determine who will reassess the risks and decide whether on-site employee(s) must be trained in first aid.

First-aid supplies and equipment

First-aid supplies and equipment must meet the specific needs of the company’s operations and hazard risks.

Determine who is responsible for ensuring that adequate first-aid supplies are readily available and keep a list of first-aid supplies.

Determine what facility the supplies are kept at and their location.

Determine who is responsible for ensuring the first-aid supplies are adequate and supplies are replaced promptly when expended.

Determine what the first-aid program should include. If the facility has injurious corrosive materials, it must have drenching and flushing equipment that meet the specifications of American National Standards Institute (ANSI) Z358.1.

Determine the location that emergency eyewash and shower equipment is installed at.

Designated employees who respond to emergencies or clean up after them have the potential for exposure to blood and body fluids. For their safety and protection, determine what personal protective equipment will need to be provided.

Posting

To help those responding to a medical emergency, post signs directing personnel to emergency equipment and supplies. Document the signs you have posted, their message and their location.

Training

Training is the heart of First-Aid Programs. Employees must not attempt to rescue or treat an injured or ill employee unless they are trained and qualified to do so. Employees are trained to contact a designated qualified individual.

Employees who are trained and qualified to render first aid have completed a first-aid training program. Determine who is responsible for conducting training and what their qualifications include. Determine the frequency of the first-aid training and a description of what the training program includes.

Training certification

After an employee has completed the training program, determine who will certify that the employee can successfully render first aid. An individual responsible for keeping records verifying certification of employees who have completed training should be appointed.

Each certificate should include the name of the employee, the date(s) of the training, and the signature of the person who performed the training and evaluation.

Retraining

Trained employees should receive refresher training frequently to keep their skills and certification current.

First-aid procedures

Document what the workplace first-aid procedures include.

Accident reporting

Employees should be trained to report all injuries and illnesses to management, including first-aid cases and near-miss events. Injuries and illnesses involving a fatality, medical treatment, days away from work, or job transfer, must be reported to the employee’s supervisor immediately.

Recordkeeping

Designate an individual that is responsible for maintaining records relating to the company’s first aid, injury, illness, and accidents cases.

Program evaluation

Ensure the First-Aid Program is effective by thoroughly evaluating and revising the program as necessary. Determine the frequency the evaluation is performed and what evaluation elements should be included.

Active shooter response

In a letter of interpretation dated June 19, 2019, OSHA responded to a question about response times for life-threatening bleeding, including active shooter situations. OSHA reiterated its policy of 3-4 minutes, noting that these are maximums and that shorter response times are encouraged.

OSHA recommends that an emergency response plan include preparing for active shooter incidents, such as shelter-in-place and evacuation procedures. The agency noted that during an active shooter incident and evacuation, employees who voluntarily choose to stay behind to assist the wounded would be considered acting as “Good Samaritans.” OSHA also noted that its standards apply only to employees and not to non-employee bystanders.

Finally, OSHA said that a response time of less than three minutes would likely require onsite trained first-aid employees at every work site. OSHA recommends, but does not require, that every workplace include one or more employees who are trained and certified in first aid, including CPR.